Category: IP CAH

From: CMS Transmittal 138 (Pub. 100-07) – 4/7/15

Summary of Changes:

Appendix W, Survey Protocol, Regulations and Interpretive Guidance for Critical Access Hospitals (CAHs) and Swing Beds in CAHs, is being revised to reflect recent regulation changes.  We are also taking this opportunity to make clarifications and updates to existing guidance.

Read more: Revisions to State Operations Manual (SOM), Appendix W for CAHs

From: AHA News – 2/6/15

Article Excerpt:

A bipartisan group of lawmakers have recently introduced a spate of AHA-backed legislation that supports small and rural prospective payment system (PPS) hospitals and critical access hospitals (CAH).  Securing passage of the legislation is part of the AHA’s advocacy agenda. The rural hospital relief bills include the following.

 Making MDH program, low-volume adjustment permanent.Sens. Charles Grassley, R-Iowa, and Chuck Schumer, D-N.Y., joined Reps. Tom Reed, R-N.Y., and Peter Welch, D-Vt., on Feb. 3 to introduce the Rural Hospital Access Act, S. 332/H.R. 663, legislation that would make permanent both the Medicare-dependent Hospital (MDH) program and the enhanced low-volume Medicare adjustment for small rural PPS hospitals.

Without congressional action, the current short-term extension of the programs will expire on March 31. In letters of support for the legislation, AHA Executive Vice President Rick Pollack called these “vital programs for America’s rural hospitals and the patients and communities they serve.”

Under the MDH program, about 200 hospitals that are more dependent on Medicare revenue because of the high percentage of Medicare beneficiaries in rural areas receive the sum of their PPS payment rate, plus three-quarters of the amount by which their cost per discharge exceeds the PPS rate. The enhanced low-volume adjustment helps level the playing field for hospitals in small and isolated communities, which frequently cannot achieve the economies of scale possible for their larger counterparts.

Extending the Rural Community Hospital Demonstration. Rep. Don Young, R-Alaska, introduced on Feb. 3 the Rural Community Hospital Demonstration (RCH) Extension Act, H.R. 672, which would extend the demonstration for five years.

The program enables rural hospitals with fewer than 51 acute-care beds to test the feasibility of cost-based reimbursement. Currently, 23 small rural hospitals participate.

“By extending the demonstration for five more years, your legislation will ensure that RCH continues to help America’s communities in many ways, especially by allowing hospitals to expand and improve the services rural communities need,” the AHA’s Pollack wrote the bill’s sponsor in a letter of support. The program was created by the 2003 Medicare Modernization Act of 2003 and extended by the Affordable Care Act.

Removing 96-hour certification requirement for CAHs. Sens. Pat Roberts, R-Kan., and Jon Tester, D-Mont., Jan. 27 introduced a Senate companion to the Critical Access Hospital Relief Act, S. 258/H.R. 169. The legislation would remove the 96-hour physician certification requirement as a condition of payment for CAHs.

Medicare currently requires physicians to certify that patients admitted to a CAH will be discharged or transferred to another hospital within 96 hours in order for the CAH to receive payment under Medicare Part A.

The Centers for Medicare & Medicaid Services (CMS) has not historically enforced the requirement, but in recent guidance related to its two-midnight admissions policy implied that it will, a situation that would threaten patients’ access to longer care when needed. The legislation would not remove the requirement that CAHs maintain an average annual length of stay of 96 hours, nor affect other certification requirements for hospitals.

“This absurd rule puts arbitrary limits on how many hours patients can stay in critical access hospitals, and asks doctors to be clairvoyant and predict the unknown when admitting a patient,” said Roberts, who is co-chairman of the Senate Rural Health Caucus.

Original co-sponsors include Sens. John Thune, R-S.D., Jerry Moran, R-Kan., John Barrasso, R-Wyo., Daniel Coats, R-Ind., Grassley, Thad Cochran, R-Miss., Deb Fischer R-Neb., Steve Daines, R-Mont., James Inhofe, R-Okla., Roger Wicker, R-Miss., John Hoeven, R-N.D., Heidi Heitkamp, D-N.D., and Tammy Baldwin, D-Wis.

The AHA’s Pollack wrote the bill’s sponsors that the measure would “provide important relief for (critical access hospitals) and help ensure all Americans – no matter where they live – have access to essential health care services.”

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